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Process Safety Management of Highly Hazardous Chemicals. Nancy J Bethea. Process Safety Management (PSM). Is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment. Purpose.

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process safety management psm
Process Safety Management (PSM)

Is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment.

purpose
Purpose
  • Prevent Catastrophic Releases of Highly Hazardous Chemicals
  • Minimize Consequences of Such Releases to Employees and the Community
catastrophic events
Catastrophic Events

Deaths Injuries

  • 1984 Mexico City 650 --
  • 1984 Bhopal, India 2500 --
  • 1984 Chicago area 17 17
  • 1985 West Virginia -- 135
  • 1988 New Orleans 5 23
  • 1988 Henderson, NV 2 350
catastrophic events6
Catastrophic Events

Deaths Injuries

  • 1989 Pasadena, TX 23 130
  • 1990 Houston, TX 17 --
  • 1990 Cincinnati, OH 2 72
  • 1991 Lake Charles, LA 5 --
  • 1991 Sterlington, LA 8 120
  • 1991 Charleston, SC 6 33
  • 1991 Seadrift, TX 1 32
process safety management
Process Safety Management

Bhopal (’84): focused OSHA’s attention

Institute, WV(’85): shows disasters can happen here

1988-1991: concern of public & Congress increases with each event

Feb. 24, 1992: standard in Federal Register

29 cfr 1910 119
29 CFR 1910.119

OSHA’s Process Safety

Management Standard

anticipated benefits
Anticipated Benefits

OSHA estimated that the integrated

approach of the PSM standard would reduce

the average annual number of deaths (265)

by 200 and reduce the average annual

number of serious injuries (900) by 700 in

industries involved with highly hazardous

chemicals.

resources
Resources
  • European Economic Community (EEC)
  • World Bank
  • International Labor Office (ILO)
  • U.S. Environmental Protection Agency
  • Superfund Amendments and Reauthorization Act (SARA)
  • States, Industry, & Labor Organizations
psm standard
PSM Standard

Performance

NOT

Specification Standard

psm standard12
PSM Standard
  • Process Safety Information
  • Process Hazard Analysis
  • Operating Procedures
  • Training
  • Contractors
  • Pre-startup Safety Review
psm standard13
PSM Standard
  • Mechanical Integrity
  • Hot-work Permits
  • Management of Change
  • Incident Investigations
  • Emergency Planning & Response
  • Compliance Safety Audits
what s covered
What’s Covered
  • Listed Chemicals in Appendix A
  • > 10,000 pounds of Flammable Liquids or Gases
examples of covered chemicals
Examples of Covered Chemicals

Acetaldehyde Chlorine

Nitromethane Ethylamine

Perchloric Acid Phosgene

Tetramethyl Lead Ketone

HF NO

what s not covered
What’s Not Covered
  • HC fuels used only for workplace consumption and if not a part of a covered hazardous process
  • Flammable liquids stored or transferred below NBP w/o chilling or refrigeration
  • Retail facilities
  • Oil, gas well drilling, servicing
  • Normally unmanned remote facilities
process safety information chemicals
Process Safety Information:Chemicals
  • Toxicity
  • PEL
  • Physical Data
  • Reactivity and Corrosivity
  • Thermal and Chemical Stability
  • Effects of Mixing Chemicals
process safety information process
Process Safety Information:Process
  • Block flow or process flow diagram
  • Process chemistry
  • Maximum intended inventory
process safety information process19
Process Safety Information:Process
  • Safe upper/lower limits for such items as temperatures, pressures, flows or compositions
  • Consequences of deviations, e.g. runaway reaction potential
process safety information equipment
Process Safety Information:Equipment
  • Materials of construction
  • P&IDs
  • Electrical Classification
  • Relief system design & design basis
process safety information equipment21
Process Safety Information:Equipment
  • Ventilation system design
  • Design codes and standards
  • Material & energy balances
  • Safety systems
process hazard analysis
Process Hazard Analysis

Organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of highly hazardous chemicals

process hazard analysis23
Process Hazard Analysis
  • Causes/consequences of fires & explosions
  • Releases of toxic or flammable chemicals
  • Major spills of hazardous chemicals
  • Methodology depends on the process & its characteristics
pha focuses on
PHA Focuses On
  • Equipment
  • Instrumentation
  • Utilities
  • Human Actions
  • External Factors
process hazard analysis25
Process Hazard Analysis
  • What If?
  • Checklist
  • What If?/Checklist
  • Hazard & Operability Study (HAZOP)
  • Failure Mode & Effects Analysis (FMEA)
  • Fault Tree Analysis (FTA)
pha must address
PHA Must Address
  • Hazards of the process
  • Engineering & administrative controls
  • Consequences of failure of controls
  • Facility siting
pha must address27
PHA Must Address
  • Human factors
  • Evaluate potential effects to on-site personnel from failure of controls
  • Identification of previous incidents
pha team
PHA Team
  • Expertise in engineering & process operations
  • One member to have knowledge of & experience with process being evaluated
pha team29
PHA Team
  • One member knowledgeable in specific PHA methodology used for evaluating the process
  • Other members with specific knowledge: instrumentation, chemistry, etc.
employer pha actions
Employer PHA Actions
  • Establish system for prompt response
  • Ensure timely resolution of findings & recommendations
  • Document actions taken
employer pha actions31
Employer PHA Actions
  • Develop written schedule for completions
  • Complete actions ASAP
  • Communicate actions to affected employees
operating procedures
Operating Procedures
  • Provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information
  • Address at least the listed elements
operating procedures steps for each operating phase
Operating Procedures:Steps for Each Operating Phase
  • Initial startup, operation, shutdown
  • Temporary & emergency operations, emergency shutdown
  • Startup following shutdowns
operating procedures operating limits
Operating Procedures: Operating limits
  • consequences of deviations
  • prevention of deviations
operating procedures safety health considerations
Operating Procedures: Safety & Health Considerations
  • Chemical properties and hazards
  • Precautions to prevent exposure
  • Control measures if contact or airborne exposure occurs
operating procedures safety health considerations36
Operating Procedures: Safety & Health Considerations
  • Quality controls for raw materials
  • Control of hazardous chemical inventories
  • Special or unique hazards
  • Safety systems & their functions
operating procedures37
Operating Procedures
  • Operating procedures readily accessible
  • Reviewed as necessary to reflect current procedures and changes
  • Certified annually as current & accurate
operating procedures38
Operating Procedures
  • Develop & implement safe work practices to provide for the control of hazards during operations, e.g. lockout/tagout/ confined space entry, opening equipment & pipes, facility entry
  • Apply to employees & contractor employees
training
Training
  • Process overview
  • Process hazards
  • Operating procedures
  • Emergency procedures
  • Refresher training at least every 3 yrs
  • Documentation
employer responsibilities
Employer Responsibilities
  • Evaluate contractor’s safety performance & programs
  • Inform contractor of potential hazards: fire, explosion, toxic release, applicable plant safety rules
  • Develop/Implement safe work practices
  • Evaluate contractor performance
contractor responsibilities
Contractor Responsibilities
  • Advise employer of any unique work hazards of contracted work
  • Each employee follow all applicable work practices & safety rules of the facility
  • Ensure each employee is trained in necessary work practices
contractor responsibilities42
Contractor Responsibilities
  • Ensure each employee is instructed in known fire, explosion, or toxic release problems related to his/her job
  • Document that understanding of training has been evaluated, verified
pre startup safety review
Pre-startup Safety Review

Done when:

  • New processes
  • Modified process
pre startup review verifies
Pre-startup Review Verifies
  • Construction: conforms to design
  • Procedures: adequate, in place
  • PHA recommendations resolved or implemented
  • Management of change requirements met
  • All affected workers trained
psm mechanical integrity
PSM Mechanical Integrity
  • Pressure vessels, storage tanks
  • Piping systems, components
  • Relief & vent systems, devices
  • Emergency shutdown systems
  • Controls: monitoring devices, sensors, alarms, interlocks
  • Pumps
mechanical integrity
Mechanical Integrity
  • Written procedures
  • Training: process hazards, job tasks
  • Inspections
  • Testing
  • Corrective action
  • Records
hot work permits
Hot Work Permits
  • Welding, cutting, brazing
  • Control of ignition sources
  • Verify safe conditions
  • Authorization
management of change
Management of Change
  • Establish written procedures
  • Develop management support
  • Evaluate safety of any changes to:

process chemicals facility

technology equipment

moc procedures must address
MOC Procedures Must Address
  • Everything except “replacement in kind”
  • Temporary as well as permanent changes
  • Technical basis for change
  • Safety & health effects
moc procedures must address50
MOC Procedures Must Address
  • Modified operation procedures
  • Time necessary for change
  • Authorization for change
  • Ways to inform & train workers before change
incident investigation goals
Incident Investigation Goals

Identify incident causes and implement steps to prevent reoccurence

incident investigation
Incident Investigation
  • Every incident
  • Prompt investigation
  • Knowledgeable team
  • Documentation & report
  • Recommendations & findings
  • Resolutions & corrective actions
emergency planning response
Emergency Planning & Response
  • Develop Emergency Action Plans
  • Pre-plan for catastrophe
  • Train & equip workers
  • Drills
compliance safety audits
Compliance Safety Audits
  • Certify all elements of standard
  • Knowledgeable audit team
  • Report & recommendations
  • Address all finding & recommendations
  • Conduct every three years
appendices
Appendices

A: List of chemicals

B: Sample block & flow diagrams

C: Compliance guidelines

D: References

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